U.S. to issue regulations on foreign tax credit and section 901(m)

The U.S. IRS on July 21 released an advance copy of Notice 2014-44, announcing that the government will issue regulations to prevent taxpayers from engaging in transactions following covered asset acquisitions that are intended to invoke the application of the statutory disposition rule under section 901(m)(3)(B)(ii) but avoid the purpose of section 901(m).  Notice 2014-44